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Introduction

SECTION 15. REQUESTS FOR

Internal Revenue Bulletin 2013-50 · 2026-10-03 edition · updated 2026-10-04 · United States

RULINGS

.01 In General . Requests for advance rulings regarding the interpretation of a tax treaty, as distinguished from MAP requests under this revenue procedure, must be submitted to the Associate Chief Counsel (International) according to the provisions of the applicable revenue procedure governing such submissions. See Rev. Proc. 2013–1, 2013–1 I.R.B. 1 (or successor guidance), and Rev. Proc. 2013–7, 2013–1 I.R.B. 233. .02 Foreign Tax Rulings . Neither the U.S. competent authority nor any other office within the IRS will issue an advance ruling on the effect of the provisions of a U.S. tax treaty on the application of the domestic tax laws of a treaty country.

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